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The House Committee on Energy and Commerce
Full Committee on Energy and Commerce
September 4, 2003
09:30 AM
2123 Rayburn House Office Building
I would like to thank the Committee for inviting the Independent Market
Operator of Ontario to join this panel. My name is David Goulding, and I am the
President and CEO of the IMO since its inception over four years ago.
There is strong tradition of cooperation and trade in electricity between
Ontario and its U.S. neighbours. Our interconnections have yielded significant
benefits to all parties over the years benefits that can and should be preserved
as we move forward. I say this even though Ontario was one of the jurisdictions
hardest hit when this disturbance cascaded across our borders.
Today, I'll provide a quick background on how Ontario fits into the North
American grid and markets, then proceed to address the six questions that were
in the chairman's letter of invitation.
1. Ontario is Fully Integrated into the U.S. Grids and Markets
With a population of 11 million people, Ontario has an electricity system
roughly equal in size to New England's. Annual use is about 150 TWh, valued at
over CAD $11 billion. The generation mix in Ontario is made up of nuclear, coal,
hydroelectric and natural gas. Trade with our neighbouring jurisdictions is
considerable, amounting to several hundred million dollars/year. For example, in
the last twelve months, Ontario has traded the following volumes with its
neighbouring states:
IMPORTS to Ontario GWh EXPORTS from Ontario GWh
New York 1, 572 3,149
Michigan 5,436 132
Minnesota 364 23
TOTAL 7,372 3,304
Ontario's electricity system has been fully integrated with neighbouring U.S.
systems for many decades. There is significant import/export capability with the
states of New York, Michigan and Minnesota that can total up to 2700 MW. This
can supply up to 10% of Ontario's peak demand. We are active participants and
members of international standards setting and development organizations such as
North American Electric Reliability Council (NERC), Northeast Power Coordinating
Council (NPCC), and of the recently formed Regional Transmission Organization (RTO)
Council of all operating Regional Transmission Organizations in North America.
Electricity is predominately under provincial jurisdiction in Canada, with
the federal National Energy Board (NEB) exercising a role limited to export
permits and international facility approvals. The Ontario Energy Board (OEB) is
the main regulatory agency for electricity in Ontario, although substantial
regulatory functions, including reliability, are carried out by the IMO.
While Ontario utilities are not under the jurisdiction of FERC, the
Commission, in a recent decision, found that the IMO operates markets that meet
their criteria for providing non-discriminatory access to U.S. entities as well
as to Ontario entities.
2. Background on the Independent Market Operator in Ontario (IMO)
The IMO was created in 1999 as part of Ontario's restructuring of its
electricity sector, and is the functional equivalent of a U.S. based ISO or RTO
such as NYISO, PJM, or ISO-NE. The objectives of the IMO are established by
Ontario's Electricity Act, 1998. Our objectives are:
(a) to exercise and perform the powers and duties assigned to the IMO under this
Act, the market rules and its licence;
(b) enter into agreements with transmitters giving the IMO authority to direct
the operations of their transmission systems;
(c) direct the operations and maintain the reliability of the IMO-controlled
grid;
(d) establish and operate the IMO-administered markets;
(e) collect, and provide to the public, information relating to the current and
future electricity needs of Ontario and the capacity of the integrated power
system to meet those needs;
(f) participate in the development by any standards authority of standards and
criteria relating to the reliability of transmissions systems; and
(g) work with responsible authorities outside Ontario to coordinate the IMO's
activities with their activities.
Participation in and operation of the IMO-administered markets is governed by
a comprehensive set of Market Rules. A Board of Directors, made up of
independents as well as stakeholders, governs the IMO and approves the Market
Rules.
The IMO-administered markets have been in operation since May 1, 2002.
3. Specific Accountabilities Regarding Reliability
- The IMO's objects assigned to it by Provincial legislation include
participating in the development of standards and criteria relating to the
reliability of transmissions systems, as well as directing the operation and
maintaining the reliability of the IMO-controlled grid.
- The IMO's licence, granted by the Ontario Energy Board (OEB), obligates
the IMO to enter into agreements with Transmitters for purposes of directing the
operation of the grid.
- An extensive set of Market Rules goes into considerable detail related to
reliability obligations, authorities, monitoring and enforcement. A copy of
these Market Rules is on the IMO website (www.theimo.com). A copy has been filed
with FERC for information.
- The IMO has full statute-based authority for establishing, monitoring and
enforcing reliability standards. In this regard, the IMO has been an active
participant in NERC and NPCC and has adopted the standards developed through
those organizations as the basis for reliability standards in Ontario.
- The IMO is Ontario's Control Area operator, and is party to the Northeast
Power Coordinating Council (NPCC) agreement.
- The IMO is also the reliability coordinator for Ontario and was subject of
a NERC reliability coordination audit in October, 2002.
- A 2002 reliability compliance audit by the NPCC concluded that the IMO's
procedures and practices are exemplary in discharging its reliability authority
functions. Its conclusion is that "the Ontario Area compliance program is
unique in that it is directly tied to the established market rules and licensing
requirements. This structure makes compliance a binding obligation and
facilitates in the administration and enforcement of compliance. NPCC's
Compliance Monitoring and Assessment Subcommittee (CMAS) encourages other Areas
to consider such a compliance program model".
Question 1
What exactly were the specific factors and series of events leading up and
contributing to the blackouts of August 14?
The Committee will hear from NERC on September 3rd, the day prior to this
testimony.
The IMO, along with many other entities, is working with NERC to put a
complete picture of events together. Our technical experts and our data are
being made available for this purpose.
This testimony expands on the Ontario perspective on the disturbance and how we
worked with our neighbours to restore service to customers.
Question 2a
At what time did your company first become aware that the system was
experiencing unscheduled, unplanned or uncontrollable power flows or other
abnormal conditions.
Answer to 2a
Subsequent analysis of data indicates that the disturbance started at
approximately 4:09 pm, and for the next several minutes, the following sequence
occurred:
· The flow into Ontario from Michigan reversed, from a flow into Ontario of
about 486 MW to a flow out of Ontario which increased over time, reaching over
2200 MW about 3 minutes into the disturbance period.
· Voltages across Southwestern Ontario declined.
· Flow into Ontario from New York first increased by 700 MW and stayed there
for a minute or so and then increased further. Shortly after, the flow reversed
to be from Ontario out to New York, settling at about 1,200 MW.
· During this time, voltage instability occurred in Ontario, and frequency
declined causing automatic frequency protections to operate in Ontario in an
attempt to arrest the decline by shedding load.
· Various generating units and transmission lines started tripping off-line to
protect equipment.
· Separation of Ontario from Michigan occurred at around 4:12 pm.
· Ontario is largely blacked out by 4:12 pm.
· Small pockets of Ontario remained connected to New York and in Northwest
Ontario to Minnesota and Manitoba.
Question 2b
What steps did you take to address the problem?
Answer to 2b
Steps taken to address the problem:
· Confirmed extent of the disturbance
· Activated the Ontario Power System Restoration Plan including:
- Communication with other Control Areas (CAs)
- Communication with Transmitters
- Communication with market participants in Ontario
· In order to restore power reliability to customers throughout the Province,
the priorities of the restoration plan are:
- Restore Class IV AC power to all nuclear sites
- Restore power to critical transmission and generating station service loads
- Restore critical utility owned telecom facilities
- Restore customer loads to the extent necessary to control voltages and secure
generating units
- Synchronize islands together and/or to adjacent power systems
· Suspended Ontario's IMO-administered Markets at 4:20 pm
· Activated the IMO's internal Emergency Response Team and our external
Crisis Management Support Team (within minutes):
- Focus on public health and safety
- Early notification to provincial and federal government regarding scope and
scale of the blackout
- Early notification to telecommunications service providers to sustain critical
telecom
- Identification of status of priority loads at several stages through
restoration (e.g. hospitals, oil and gas refineries, and water treatment plants)
· Set up Decision Support and Communication Centre with Ontario government
officials, including working with industry and government to assist in
implementation of the Ontario government's voluntary conservation/curtailment
program over the week following the disturbance.
Service was restored to all customers in Ontario by end of Friday, August
15th, with the voluntary curtailment request from government being lifted on
Friday, August 22nd.
Question 2c
Were there any indications of system instability prior to that time?
Answer to 2c
There were no indications of system instability prior to that time.
Pre-disturbance conditions:
· All reserve requirements were being met (1,580 MW)
· Operating within all system limits
· System voltages were within required ranges
· No significant transmission outage
· Actual Ontario demand - 24,050 MW
· Schedules: from Michigan - 1, 074 MW, from New York - 373 MW
· Actual Flows: from Michigan - 486 MW, from New York - 1,089 MW
Question 3
Which systems operated as designed and which systems failed?
Power System Protections
Protections intended to isolate equipment from damage worked as designed. These
protections provided a safe and orderly shut down for generators, transformers,
and transmission lines.
Emergency Power Supply to Control Centre
Back-up battery/diesel systems worked seamlessly at the IMO's Control Centre,
providing electrical power to enable the IMO to direct the restoration of
Ontario's power system.
Public Telephone System
With the exception of cell phones that were overloaded early in the event, the
public telephone network was generally available to the Control Centre.
Subsequently, the heavy traffic made arranging large conference calls difficult.
System Restoration and Crisis Management Processes
- Efficient and effective assignment of accountabilities within the control
room
- Good cooperation from field staff of generators and transmitters
- Good cooperation with neighbouring area operators
- Successful restoration plan
Large-scale restoration is inherently complex, and our control room staff
adapted to changing circumstances as the restoration proceeded, modifying
approaches as necessary to achieve objectives. The overall restoration and
crisis management processes proceeded in an orderly fashion and met their
objectives.
IMO Help Centre
The IMO Help Centre was immediately able to expand its operations from weekdays
to 24x7, and successfully handled a 400% increase in call volumes over the
ensuing 8 days. As a result there was always someone available to answer
questions during the declared emergency, and all questions were handled quickly.
The IMO Help Centre typically answers calls from IMO customers. During this
period significant volumes also came from large industrial consumers, small
businesses and the general public. The overriding request was for information to
help them ensure that they, as electricity users, were "doing the right
thing," such as implementing conservation measures.
The communication systems that the IMO Help Centre relies on to receive and
reply to inquiries (i.e. phone and e-mail) functioned normally during the entire
emergency.
Communication Centre / Provincial Decision Support
A Communications Centre was set up to brief media on status of system
restoration in Ontario and to provide information as to how customers can assist
in the restoration effort. Press conferences, scheduled twice daily, were
coordinated with Provincial officials.
Provincial government officials were continuously briefed on power
restoration priorities to ensure coordination with other government agencies.
Question 4a
If events similar to those that occurred on August 14, 2003 had happened a year
ago, would the results have been the same?
Answer to 4a
No comprehensive analysis of the initiating and subsequent events is yet
available. This question can only be answered in a meaningful way once that
analysis, now underway at NERC, is complete.
Question 4b
If similar events occur a year from now, do you anticipate having in place
equipment and processes sufficient to prevent a reoccurrence of the August 14
blackout?
Answer to 4b
Ontario's intent is to incorporate lessons learned from this event, and to
follow up on all recommendations designed to avoid a re-occurrence. But
Ontario's actions, and those in our neighbouring jurisdictions, must be part of
wider regional actions and solutions. It will not be sufficient if even a few
entities fail to address the lessons learned. Actions must be taken by all
interconnected jurisdictions.
Question 5
What lessons were learned as a result of the blackouts?
It is too early to know all the lessons learned at this time. Only by thoroughly
studying the events of August 14th and getting to the root cause of the events
will the lessons become apparent. We can, however, confirm the value of various
plans and practices from Ontario's perspective:
1. We confirmed that the devices that are in place to protect equipment operated
as planned.
2. We confirmed that maintaining a well-documented restoration plan,
supported by training and rehearsals involving the IMO, market participants and
government, was and will continue to be a key investment.
3. We confirmed that close cooperation amongst the IMO, and Ontario
Transmitters, Generators, market participants and government is essential to
achieving an orderly restoration.
4. The significance of communication protocols between different control
areas and reliability coordinators became evident.
5. Maintaining a secure power system in a strongly interconnected network is
difficult when there is imperfect knowledge about the extent of local
disturbances that have the potential to spread regionally. The extreme speed at
which events can cascade across the system increases the significance of timely
information.
Question 6
How can similar incidents in the future be prevented?
While additional lessons will be identified as the event analysis proceeds,
it is the submission of the IMO that the following principles should be adopted
by the Committee, and acted on at the earliest possible date:
1. Maintain and enhance the integration of systems and markets:
The interconnections with our neighbours have yielded substantial reliability
and trading benefits for all parties over the years. These benefits are
significant and must be preserved.
2. Mandatory enforceable reliability standards should be put in place where
they do not exist:
- Reliability standards for the interconnected North American grid should
continue to be developed through the NERC international processes and the
associated regional reliability councils but those standards should no longer be
voluntary, they should be mandatory.
- A well-defined statute-based mandate should be established in the U.S.
under which a responsible organization would have clear enforcement, compliance
and sanctioning authority for reliability performance. This mandate should be
compatible with the corresponding Ontario mandate with respect to Ontario
entities.
- Ontario already has in place a statute-based authority to support the
development and enforcement of reliability standards. Under Ontario law, the IMO
establishes reliability standards, and can and does enforce those standards.
Ontario standards established and enforced by the IMO meet or exceed relevant
NERC and NPCC guidelines and policies. The IMO has all necessary authorities to
impose sanctions on asset owners for non-compliance.
- The U.S. reliability standards language in the current U.S. House and
Senate Bills allows for the creation of an international organization that
properly reflects the multi-national nature of the grid.
3. The industry should continue to pursue the three part strategy of
prevention, containment and minimization of impact:
prevention: through good planning and operations, adequate investments and
putting in place mandatory enforceable standards.
containment: through monitoring capabilities, communication protocols, as
well as equipment and processes that are set to limit the scale of disturbances.
minimization of impact: through good restoration plans, practical training,
education and communications.
4. The industry should build on the strong institutional and regulatory
foundations already in place:
It is our view that the framework exists to provide for improvements and future
prevention of similar incidents. The strong and long tradition of international
cooperation has served North America well. The institutions, agreements, and
organizations already in place, supplemented by well-defined authorities as
necessary, are fully sufficient, in our view, to take the industry forward.
This concludes my prepared remarks. I am prepared to answer questions at this
time.
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